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By Dr. Sebastiaan Niels HOOGHIEMSTRA*
On 19 December 2025, the CSSF issued Circular 25/901 (the “Circular”), a major overhaul that modernizes, clarifies and simplifies rules for all CSSF-regulated investment funds (“Regulated Funds”), including SIFs, SICARs and Part 2 UCIs. The Circular repeals several long-standing circulars, renders others inapplicable, and introduces a comprehensive general glossary aimed at streamlining communication with the CSSF. While the Circular primarily targets SIFs, SICARs and Part 2 UCIs, it is also (partially) relevant for RAIFs. This contribution focuses on the risk capital notion applicable to SICARs, which is equally relevant for SICAR-like RAIFs. For ease of reference, references in this contribution are made to SICARs, with...
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